CONSEQUENCES OF BREXIT FOR FOOD LABELLING / by Nikolaas Tilkin-Franssens

Following a range of guidance documents to prepare businesses for the actual Brexit in March 2019, UK authorities have provided a notice specifically addressing the repercussions for food labelling. The guidance leaves from the possibility that no arrangements would be made with the other EU member states,and thus EU law would no longer apply to the UK. Considering many of the EU rules, especially on compositional standards, are transposed into UK acts EU rules will largely remain applicable. As the UK will no longer be part of the European Union, the use of the term ‘EU’ will however no longer be of use for UK produce such as in the case of honey blends.

In addition, all products originating from other EU countries would need to include a UK address of a responsible food business operator. UK products on the other hand would require the inclusion of the address of a EU responsible operator in order to be legally marketed in the EU. Though the notice states that in consultation with UK retailers, a transitional measure may be considered and foods already placed on the UK market with the address of a EU responsible operator may be sold until exhaustion of available stocks. Furthermore, natural mineral waters originating from the UK will need recognition by another EU member state to maintain their status within the EU.

Guidance (24 September 2018) - Producing and labelling food if there's no Brexit deal - link